Clemson University
INCENTIVE CARDS POLICY
Effective: 1/1/14
Revised: 12/29/20
Related Procedure
Incentive Card Order Process
I. Overview
Incentive cards may be used as a tool to meet the business purposes of the University. They can be used to support research study subjects and for awards or prizes to support student activities. As cash-equivalent instruments, incentive cards are governed by internal control requirements and may be subject to tax reporting. They must be distributed in accordance with the guidelines set forth in this policy.
II. Policy General
Incentive cards must be purchased through buyWay$ from the National Gift Card Company (NGC). (Exemptions may be available in situations in which external funding pre-dated this policy or required purchases cannot be accommodated by the NGC). Personal reimbursements and direct purchases outside of the established buyWay$ process are not allowed. Incentive cards must only be requested when disbursement of such funds is expected to occur within ninety (90) days from the time the cards are received. If the project or need to distribute continues beyond that time frame, multiple incentive requests must be made to provide for a reasonable and timely accounting of funds.
1. Research Subjects: An incentive may be offered to research subjects, provided it was included as part of the grant award and Institutional Review Board (IRB) approval was obtained. This policy is intended to provide guidance as to the appropriate acquisition and distribution of research subject incentives.
2. Non-Research Subjects: It is also common, based on the specific mission and goals of specific areas of the University, to utilize incentives to encourage or award individuals for participating in certain events. Unlike with research subjects, these incentives are not bound by grant awards and IRB approval. This policy is intended to provide guidance as to the appropriate acquisition and distribution of non-research subject incentives.
III. Allowable Uses and Limits
Incentive cards may only be distributed for the following purposes:
1. Incentive for research subjects in studies approved by the University’s Institutional Review Board (IRB)
2. Prizes, recognition awards or tokens of appreciation for students
3. Prizes, recognition awards or honorarium for volunteers or visitors
4. Incentive for employees participating as a volunteer in a research study or event unrelated to their job
Individual incentive cards should be valued at $100 or less. They cannot be used as a bonus, awards, honoraria, or other means of compensation to employees. These payments must be processed through the payroll system. If there is any question about a particular situation, please consult with Human Resources.
Ensuring proper controls is important in the use of incentive cards and IRS reporting is critical in compliance with IRS and federal reporting requirements. For any individual that is disbursed $600 or more in a calendar year, the department's responsible person must follow the steps identified in section E.2 of the Related Procedure to ensure the proper tax treatment is performed by Clemson University.
IV. Internal Controls
Incentive cards must be safeguarded at all times and accounted for as if they were cash. The person accountable has primary responsibility for safekeeping, maintenance and proper usage and for advising faculty, staff or students of proper handling policy and procedure. For grants, the Principal Investigator (PI) must maintain all records regarding the research subjects.
The following controls are required at a minimum:
A. Custody: The person accountable holds custody over the cards and should always know where they are located. Custody may be transferred temporarily from the person accountable to other departmental personnel for disbursement purposes, but the person accountable still holds primary responsibility for the safekeeping of the cards.
B. Physical Access: Incentive cards must be secured at all times (e.g. in a locked box in a locked cabinet or drawer) with limited access. They must not be taken home for safekeeping.
V. Lost Cards
The person accountable will be held liable for any incentive cards in their possession that are lost or misplaced. Any shortage must be reported immediately to their Business Officer. The Business Officer will then notify Internal Audit. Depending on the circumstances, punitive action including loss of ordering privileges, termination and prosecution could result.
VI. Definitions
A. Incentive card: a stored-value or similar instrument issued in lieu of cash or check. For purposes of this policy, “incentive card” includes gift certificates, cash cards, and online eIncentive Cards (eCards).
B. Person accountable: the faculty or staff member in the department disbursing the incentive cards that is responsible for the documentation, internal control and other requirements of this policy. For research purposes, the Person Accountable is the Principal Investigator (PI).
C. Research subject: an individual with whom an investigator conducts research and obtains data through intervention or interaction with the individual.
V. Contact Information
Safekeeping of Cards: Cash & Treasury Services
Order Cards & Tax Reporting: Procurement & Business Services
Research Reporting: Internal Review Board